G.R. No. 172035 - Miguel vs. Sandiganbayan

Petitioners Melky Concha and Romeo Managuelod were convicted by the Regional Trial Court of Cabagan, Isabela, for the crime of carnapping and subsequently had their conviction affirmed by the Court of Appeals.
The petitioners later filed a Petition for Review on Certiorari before the Supreme Court under Rule 45 of the 1997 Rules of Civil Procedure, challenging both the January 31, 2013 Decision and the July 5, 2013 Resolution of the Court of Appeals.
The petitioners contended that their identification by the key witness was tainted by improper police suggestion during an out-of-court identification (police show‑up), which they argued violated their right to due process and resulted in a flawed conviction.

Two criminal Informations were filed charging multiple accused—including petitioners Concha and Managuelod—with two counts of carnapping under Republic Act No. 6539 (the Anti-Carnapping Act of 1972).
The offense occurred on or about February 15, 2006, in Tumauini, Isabela, where Michael Macutay, driving a Honda Wave motorcycle (plate no. BI‑8085, owned by Eugenio Cacho), was confronted by a group of armed men.
The accused, in concert with accomplices, used firearms to intimidate Macutay, ordering him to comply; they robbed him of his personal belongings (including a Seiko watch, t-shirt, wallet, and license) and took the motorcycle by force.
Evidence later surfaced when police in Cabagan discovered the motorcycle’s plate in the trunk of a white Mitsubishi Lancer, linking it to the crime scene.

Michael Macutay, the key eyewitness, testified regarding the events on the night of February 15, 2006, including the robbery and the subsequent abandonment of the motorcycle after he jumped from the scene.
On February 21, 2006, Macutay was taken to the Cabagan Police Station where he was presented with only four persons (a police show‑up) for identification, among whom he pointed out Concha and Managuelod.
The defense contended that Macutay’s identification was affected by the suggestiveness of the procedure since no proper lineup (with a wider pool of potential suspects) had been conducted.
Additional testimony by SPO4 Juan C. Anapi corroborated that only the four detained individuals (including the petitioners) were presented to Macutay, thereby potentially conditioning his identification.

Concha testified that on February 19, 2006, he was stopped by police near a bridge while returning from his field activities, forcibly taken to Cabagan Police Station, detained, and intimidated into signing a document without knowing its contents.
Managuelod similarly testified that he was arrested at his home on February 19, 2006, detained, and alleged to have been physically mistreated by SPO4 Anapi during his incarceration until February 21, 2006.
Both petitioners denied any involvement in the crime, denying that their identification by Macutay was reliable, given that they had no pretrial encounter or opportunity to be described by the witness before detention.
The prosecution, relying heavily on Macutay’s in‑court identification, argued that the witness had clearly recognized the petitioners as part of the group that committed the carnapping.

The Regional Trial Court noted that although evidence such as the discovery of the motorcycle plate was offered, the prosecution failed to prove that the accused ever possessed the plate prior to its discovery.
The conviction rested primarily on Macutay’s identification, despite inconsistencies such as the lack of an initial descriptive report by Macutay when he first reported the crime, and questions regarding his state of mind (fear, confusion) during the incident.
The identification was later scrutinized by the Court of Appeals, which held that the identification was valid, stating that there was no evidence of police suggestion, and that the procedure in a police show‑up (in contrast to a lineup) was acceptable.
However, petitioners argued that even if a police show‑up is permissible in general, in this case it was executed in a manner that induced the witness to identify them through coercive suggestion.

After the RTC rendered its November 10, 2010 Joint Decision finding the petitioners guilty, the Court of Appeals affirmed the decision on January 31, 2013.
A motion for reconsideration was subsequently denied by a July 5, 2013 Resolution.
Petitioners then elevated the case to the Supreme Court, arguing that the misapprehension of facts regarding the identification process resulted in a violation of their due process rights, thus warranting their acquittal.

Whether the out‑of‑court identification of petitioners, conducted as a police show‑up and not a proper lineup, was tainted by impermissible suggestion by police officers.
Whether such suggestiveness compromised the accuracy and credibility of Michael Macutay’s identification, thereby violating the petitioners’ right to due process.

Sufficiency of the Prosecution’s Evidence in Establishing Guilt Beyond Reasonable Doubt

Whether, notwithstanding the identification procedure’s deficiencies, the totality of the evidence was sufficient to prove beyond reasonable doubt that petitioners committed the crime of carnapping.
Whether the failure to secure corroborative elements—such as a reliable description from the witness—renders Macutay’s in‑court identification (which was predicated on the out‑of‑court identification) insufficient.